Written Submission On Behalf of The Prosecution

19TH HENRY DUNANT MEMORIAL MOOT COURT COMPETITION 2019
TEAM CODE:
No. ICC-
_________________________________________________________________________
IN THE HON'BLE INTERNATIONAL CRIMINAL COURT

TRAIL CHAMBER,
AT HAGUE.
___________________________________________________________________________
PROSECUTION
Vs.
Z. KARMONIC
-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

Table of Contents
LIST OF ABBREVIATIONS...................................................................................................3
INDEX OF AUTHORITIES....................................................................................................4
STATEMENT OF JURISDICTION.......................................................................................6
IDENTIFICATION OF ISSUES.............................................................................................7
STATEMENT OF FACTS.......................................................................................................9
SUMMARY OF ARGUMENTS............................................................................................10
I. 1 Whether Mr. Z. Karmonic has committed the crime of Genocide under Article
6(a) of the ICC Statute by allegedly killing the followers of Rokum Religion on
night of 25 May, 2018?
II. Whether Mr. Z. Karmonic has committed the offence of War Crime under
Article 8(2)(b)(ii) by intentionally directing attack against nuclear energy?
III. Whether Mr. Z Karmonic has committed the offence of War Crimes under
Article 8(2)(b)(iv) by intentionally launching an attack against the nuclear energy
plants of Rokumba with the knowledge and intention of causing incidental loss of
life and injury to civilians and widespread, long-term and severe damage to the
natural environment that is excessive to the concrete and direct military
advantage anticipated?
LIST OF ABBREVIATIONS

Art. Article
Arts. Articles
Doc. Document
Ed. Editor
Et al And others
V./Vs. Versus
ANR. ANOTHER
HON’BLE Honourable
EDN. Edition
ICC International Criminal Court
ICJ International Court of Justice.
ICRC International Committee of the Red Cross
Id Ibidem
ILA International Law Association
ILC International Law Commission
J. Judge
UN United Nation
UNSC United Nation Security Council
SoS Sarozula Of Sohus
PCIJ Permanent Court Of International Justice
LIST OF AUTHORITIES

A. CASES
1. Georges A. N. Rutaganda, Case No. ICTR-96-3-T, Trial Judgment, 06-12-1999, Para
59
2. Aloys Simba, Case No. Ictr-01-76-A, Appeal Judgement, 27 Nov. 2007
3. Radislav Krstid, Case No. IT-98-33-A, Trial Judgement, 2 Aug. 2001, ¶ 590; Krstid,
AJ ¶¶ 19, 22.
4. Goran Jelisid, Case No. IT-95-10A, Appeal Judgement, 5 July 2001
B. BOOKS
C. STATUTES
D. DYNAMIC LINKS
1. www.scconline.com
2. www.manupatra.com

STATEMENT OF JURISDICTION
The Hon’ble International Criminal Court exercises jurisdiction to hear and adjudicate the
present matter under the provisions of Article 5 read with Article 13 of Rome Statute of
International Criminal Court, 1998. The provision under which the prosecution has
approached the Hon’ble Court has been reiterated herein below.
 Article 5:
Crimes within the jurisdiction of the Court
The jurisdiction of the Court shall be limited to the most serious crimes of concern to
the international community as a whole. The Court has jurisdiction in accordance with
this statute with respect to the following crimes:-
(a) The Crime of Genocide;
(b) Crimes against Humanity;
(c) War Crimes;
(d) The Crime of Aggression.
 Article 13
Exercise of Jurisdiction
The Court may exercise its jurisdiction with respect to a crime referred to in Article 5
in accordance with the provisions of this statute if:

(b) A situation in which one or more of such crimes appears to have been
committed is referred to the Prosecutor by the Security Council acting under
Chapter VII of the Charter of the United Nations
IDENTIFICATION OF ISSUES
IV. Whether Mr. Z. Karmonic has committed the crime of Genocide under Article
V. Whether Mr. Z. Karmonic has committed the offence of War Crime under
VI. Whether Mr. Z Karmonic has committed the offence of War Crimes under

STATEMENT OF FACTS
For the sake of brevity and the convenience of this Hon’ble Court the facts of the present
case are summarized as follows:
I. INTRODUCTION
 Country Sohulwa is a democratic country and it is situated at the eastern coast of
continent Z. This eastern portion of continent Z comprises of 4 countries, namely
Sohulwa, Sambhota, Zumanja and Rokumba. This portion of continent Z is also
known as Sarozula subcontinent because all these 4 countries are surrounded by the
mountain ranges of Sarozas from all the directions except East. Ocean X makes its
boundary in the east.
 Country Sohulwa and Sambhota are the two countries which share its borders with all
the other countries. While country Sambhota is a landlocked country, country Sohulwa
is a country which is covered by the land from North, West and South and in east, the
Ocean is its boundary. The Sarozas are also the source of two prominent rivers of this
subcontinent. These rivers are R1 and R2. R1 emerges from Sambhota and then enters
into Sohulwa and runs almost parallel to the border between Sohulwa and Zumanja
and finally merges in the ocean. On the other hand, R2 emerges from Sambhota and
gets merged into Ocean by going from the territory of Sohulwa. R2 runs parallel to the

border of Sohulwa and Rokumba. R2 is in south to R1 and it is further required to
mention here that the many small rivers emerged from Rokumba and gets merged in
R2 inside Sohulwa.
II. TREATY OF SAROZULA
 Sarozula subcontinent witnessed many wars for the purpose of control over natural
and other resources of the region from 1820 to 1905. During this period, Sarozula
became the most contested point among the four colonial powers active in the
subcontinent. However, these conflicts finally came to an end in the year 1905 by the
Treaty of Sarozula, which was entered into by the then active colonial powers in the
subcontinent.
 The operation of the treaty was continued even after the subcontinent attained
independence in 1955. The treaty contributed towards many aspects including the area
of control over the land, the rivers, freedom of movement of civilians from one part of
the region to another, even a multilateral deal was entered into in the name of MT
1907.
III. DEMARCATION OF LfS
 The LfS was situated between the R1 and R2 for the purpose of developing the same
as agricultural land. Persons from all the countries provide labour for the purpose of
fulfilling the food requirements of all the countries.
IV. EMERGENCE OF SoS
 The whole situation was triggered because of the establishment of SoS. The whole
case is a glaring example of how a group promoting a particular religion leads to a
series of crimes which are against the humanity at large.
 The SoS was constituted for the purpose of promoting the religion of Saho. Its
followers were spreading their legs not only in the region of Sohulwa but also in other
three countries. The widespread function of promoting a particular religion was in

such a manner that it was leading to threat of internal peace and security therefore for
the purpose of maintaining internal peace and security, the Government of Rokumba
banned the SoS group.
V. MR. Z. KARMONIC- THE CULPRIT
 Mr. Z. Karmonic was an ardent follower of SoS and at the time when he created a
facebook page with the name and style of “Help Sarzoula”, he was the head of its
cyber wing. Posts published on this page were against the Rokumba and Rokum
religion. The base of the violence was prepared from this page by inviting the
Sohulwians to march towards the border of Sohulwa and Rokumba and ultimately, on
15th April, 2018 almost 25,000 people gathered at the border of Rokumba and
Sohulwa, majority of them were the followers of SoS, and some of them were from
Sambhota and Zumanja.
 A group in the name and style of “Help Sarozula” was created on 17 th April, 2018 and
the leader of the group was declared as Mr. Z. Karmonic. After 3 days of the creation
of group, there were series of blast occurred at various religious places in Rokumba
and on the very next day, many government buildings were put on fire in Sohulwa.
This chaos took almost 300 lives and Mr. Z was reported missing from custody. After
the release of Mr. Z, the facebook page was again reactivated and started spreading
derogatory remarks over the Rokumba and the Rokum religion. Many other attempts
were made to enter the territory of Rokumba by the marchers from the borders but all
went in vain. These scenes created a stressed atmosphere among both the countries.
 The negotiations were even tried to be made with the help of ICRC but due to the fake
posts of facebook and hacking of ICRC website, the result of the negotiations were
negative.

 On the evening of 25th May, 2018, around 600 people of Rokum religion living in
Sohulwa were killed as the Rokum religion was on target of the mob in Sohulwa. This
act on part of Mr. Z whereby the fake posts were spread across the social platform and
hacking of ICRC website, which resulted in mob provocation and hatred in the minds
of Sohulwa persons has resulted in mass murder of Rokum minorities, therefore the
action on part of Mr. Z is coming under the ambit of committing the offence of
“Genocide”.
 Despite commission of such large scale crime, the government of Sohulwa declared
him the head of the cyber cell of the Sohulwa’s armed forces. His task was to answer
the actions on part of Rokumba government. Eventually, on 15th July, 2018 there was
blasts in both nuclear energy plants in Rokumba which resulted in heavy loss of life in
Rokumba religion. After investigation, it was found by the Committee constituted by
the UNSC that the blasts were the result of cyber-manipulation which has been
originated from Sohulwa territory.
 Accordingly Mr. Z Karmonic was arrested on 10th June, 2019 and was handed over to
Hon’ble International Criminal Court. The charges were framed and Mr. Z was found
accused of committing an offence of Genocide, under Article 6(a) of ICC Statute, for
committing war crime under Article 8(2)(b)(ii) and under Article 8(2)(b)(iv).
VI. TRIAL BEFORE THE HON’BLE INTERNATIONAL CRIMINAL COURT
 After completion of all the formalities, the trial has been commenced against Mr. Z for
the aforesaid charges.

SUMMARY OF PLEADINGS
I. Whether Mr. Z. Karmonic has committed the crime of Genocide under Article
Under Article 6(a) of ICC statute, Genocide means any of the acts which has been
committed with intent to destroy, in whole or in part, a national, ethnical, racial or
religious groups and Mr. Z. Karmonic’s act is clearly falling under the ambit of Article
6(a) as:-
Firstly, the group which was constituted by Mr. Z. has led to killing of more than one
person.
Secondly, the persons who were on target were belonging to a particular religion, i.e.,
Rokum.
Thirdly, the intention of the mob was to destroy the whole community of Rokum
living in Sohulwa.
Fouthly, the conduct of the mob was the follow up of the objectives which has been
led down by SoS previously also.

II. Whether Mr. Z. Karmonic has committed the offence of War Crime under
The act of Mr. Z Karmonic was coming under the ambit of offence provided under
Article 8(2)(b)(ii) as:-
Firstly, Mr. Z. directed an attack over the minorities belonging to Rokum religion.
Secondly, the objectives behind the attack was to target people of Rokumba working in
the Nuclear Thermal Power Plant.
Thirdly, it was well known to Mr. Z that the workers working in Nuclear Thermal
power plant was belonging to Rokum religion but was not military object, even after
the same, the blasts were made by Mr. Z only for the purpose of destroying the
particular community. Hence it was the intention on part of Mr. Z to target those
objects which were not belonging to military.
Fourthly, the conduct took place in the context of international armed conflict which
has been going on since last few years between two countries.
Fifthly Mr. Z was aware of the reasons which has led to establishment of armed
conflict. In fact his incitement to the general public of Sohulwa triggered the armed
conflict between the two countries.
III. Whether Mr. Z Karmonic has committed the offence of War Crimes under
Firstly, Mr. Z. launched an attack by hacking the software of Nuclear Thermal Power
Plant which has resultantly led to blasts in the power plant.

Secondly, the heinousness of crime was to such an extent that it took hundreds of lives
in Rokumba territory.
Thirdly, not only the humanity suffered but such incident has led to huge amount of
suffering to the environment also giving a long term impact on the environment.
Fourthly, the conduct on part of Mr. Z was because of the fact that there was an arm
conflict which has taken place many a times in the past.
Fifthly, even Mr. Z was aware of the situations and facts which has resulted in
initiation of armed conflict between the two countries.

PLEADINGS
 Mr. Z. Karmonic has committed the crime of Genocide under Article 6(a) of the
ICC Statute by killing the followers of Rokum Religion on night of 25 May, 2018.
1. Article 6(a) of the Statute of ICC reads as under:-
“For the purpose of this statute, “Genocide” means any of the following acts
committed with intent to destroy, in whole or in part, a national, ethnical,
racial or religious or religious group, as such:
(a) Killing members of the group.”1
2. On 25th May, 2018 when the negotiations were ongoing between both the
countries with the help of ICRC, a fake Facebook posts carrying ICRC insignia
claimed that negotiations between the two countries have failed and the ICRC
deplored the brutal killings of all the captives at the hands of the Rokumban
government. This post was first shared on Facebook by Mr. Z. Karmonic with
the caption, “Should Fokums be taught in their own ways all over Sarozula
immediately.”2
3. By the evening of 25th May, 2018, large scale riots were spread across the
Sohulwa and Rokumban minorities were targeted by mob. It is important to
mention here that these large scale riots has been committed only on the basis
of the instructions which has been given by their leader.

1. Rome Statute of the International Criminal Court- Article 6
2. Moot Problem, P. 11 Para 2
4. It may be seen here that the mob was influenced by the group of Help Sarozula and
SoS. Mr. Z. Karmonic was having direct involvement in both these groups, he is the
leader of the Help Sarozula Group and was the head of the cyber wing of SoS Group.
It is prima facie clear that there is direct involvement of Mr. Z in the present case but
no suitable action has been taken by the Sohulwa Government against the culprit and
they were sitting tight over the matter.
5. It is further important to mention here that the respondent was well aware of the fact
that his action of inciting the general public will lead to serious destruction to the
people who belong to particular religion. Therefore his action is clearly falling under
the ambit of committing the offence of Genocide under the provisions of Article 6(a)
of the ICC Statute.
6. It is pertinent to mention here that a perpetrator of Genocide must:-
a. Intend to destroy
b. In whole or in part
c. A protected group, as such
This dolus specialis4 makes genocide different from others.
7. It is pertinent to mention here that specific intent is an element of the crime, and
required that the perpetrator clearly intended the result charged. In the case of

genocide, the perpetrator must intend that his or her actions will result in the
destructions, in whole or in part, or a protected group.5
3. Rome Statute of the International Criminal Court- Article 6
4. Specific Intent
5. Georges A. N. Rutaganda, Case No. ICTR-96-3-T, Trial Judgment, 06-12-1999, Para 59.
8. It is further important to mention here that around 600 people were killed in the chaos
which was created by a mob against the Rokum religion. The elements of Genocide
demands the killing of one or more persons and further the same must be belong to a
particular religious group. If the present case is see then it can be clearly said that:-6
8.1- More than one person has been killed, i.e., the mob took 600 lives of
Rokumban religious group living in Sohulwa.
8.2- The 600 people whose lives were taken were belonging to a particular religious
group, i.e., Rokumban religious group.
Thus, it can be held that Mr. Z is the offender who has committed the heinous
crime of Genocide under the provision of Article 6(a) of Rome Statute of ICC.
9. The important aspect which evolves here is that Genocide requires that the perpetrator
have a very specific mental state while committing the crime: a specific intent to
destroy a protected group. It is a jus cogens7 crime and its prohibition is an erga
omnes8 obligation that all states owe to the international community
10. It is pertinent to mention here that the Genocidal intent must be present at the moment
the acts are committed, but does not have to be formed prior to committing the acts. 9
Here in this case, Mr. Z was having the intention to commit the genocidal act on the
date of 25th May only when he shared the facebook post with the caption which

actually incited the general public which took the shape of mob which was targeting
the minorities belonging to Rokum religion in Sohulwa.
6. Moot Problem- Page 11- Para 3.
7. The principles which form the norms of international law that cannot be set aside.
8. Towards Everyone.
9. Aloys Simba, Case No. Ictr-01-76-A, Appeal Judgement, 27 Nov. 2007, ¶ 266;
11. Further important to note here is that to be convicted of genocide, a perpetrator must
intend to destroy a protected group entirely, or in part. As noted by the ICTY appeals
chamber, the intent to destroy a group even if only in part, means seeking to destroy a
distinct part of the group as opposed to an accumulation of isolated individuals within
it. Although the perpetrators of genocide need not seek to destroy the entire group ,
they must view the part of the group they wish to destroy as a distinct entity which
must be eliminated as such.10
12. An important factor which may be taken into consideration is that there was personal
vengeance of the respondent towards the Rokum religion. It can be clearly shown from
the fact that no other group of persons has been harmed or affected because of the fact
that they belong to non Sohu religion. The vengeance for the purpose of gaining
political benefits was strictly against the Rokumbians. Thus it is clear that the personal
motive of the perpetrator may be, for example, to obtain personal economic benefits,
political advantage or some form of power. The existence of a personal motive does
not preclude the perpetrator from also having the specific intent to commit genocide.11
13. One of the important factor which is required to be taken into consideration is that the
government of Sohulwa was also hand in glove with the respondent. The respondent
was previously behind the bars for his acts in Sohulwa Jail but at the time when there
was sudden uprising against the government, the jail were broken down and the

respondent along with his certain followers was bent missing from the jail. Thereafter
he was regularly updating his facebook page and no action has been taken by the
government to arrest the culprit respondent again.
10. Radislav Krstid, Case No. IT-98-33-A, Trial Judgement, 2 Aug. 2001, ¶ 590; Krstid, AJ ¶¶ 19, 22.
11. Goran Jelisid, Case No. IT-95-10A, Appeal Judgement, 5 July 2001, ¶ 49
 Mr. Z. Karmonic has committed the offence of War Crime under Article 8(2)(b)
(ii) by intentionally directing attack against nuclear energy.
1. Article 8(2)(b)(ii) of Rome Statute of ICC reads as under:-
“For the purpose of this Statute, “War Crimes” means:-
(b) Other serious violations of the laws and customs applicable in
international armed conflict, within the established framework of
international law, namely, any of the following acts:-
(ii) Intentionally directing attacks against the civilian objects, that is,
objects that are not military objects.”12
2. It may be seen here that for the purpose of understanding the act of respondent,
the detailed explanation of the word “Civilian Objects” is necessary. Civilian
Objects are defined in negative in the Article 8(2)(b)(ii) as “objects that are
not military objects”. Further, this Hon’ble Court in a series of judgment has
held that civilian objects are those objects which are not having its nature as
that of military personnel. Further, civilian objects are the citizens, people and
material which are not part and parcel of the military objects. If the present
case is seen, then the workers working in Nuclear Power Plant cannot be said
to be the military objects. The civilians were targeted by such blasts.

3. It may further be taken into consideration that the object of the blasts were
purely to demolish the human resources of Rokumba. It is clear and evident on
record that workers in power plant are civilian objects. The workers have no
connection with military even then the attacks were made and the life of
majority of people in Rokumba were put on stake.
12. Rome Statute of ICC, Article 8(2).
4. It is further important to mention here that the conduct of the prosecutor was of
such nature that the nuclear blasts occurred on 15th July, 2018. Thereafter for
the purpose of investigation into the matter the committee was constituted by
the UNSC for the purpose of enquiring into the reasons behind the blasts. It
was found by the expert’s committee that the blasts were the result of cyber
manipulation in the nuclear plants’ software, that originated from Sohulwa’s
territory.13
5. The cyber experts from the first committee with the help of Sohulwan security
forces found a set of 10 super computers, which were connected to each other,
in an underground room in a village near Sohulwa’s capital. The committee
alleged that these were the computers through which software programmes
aimed to target the nuclear powers plants of Rokumba were developed.14
6. The important aspect which arises out in the complete episode is that on 05 th
June, 2018, the government of Sohulwa granted a pardon to the respondent for
his past activities and made him the head of the cyber cell of the Sohulwa’s
armed forces. Thereafter the report of the first committee has provided that the
blasts were the outcome of cyber manipulation which has been arose from the
territory of Sohulwa. Therefore the involvement of respondent can be clearly
seen from the fact that the cyber manipulation on such a large scale can only be
done by an expert of cyber industry and can be done only by a person who

operates and regularize the government. In such circumstances, it can be
clearly be said that the respondent was having prima facie involvement in the
present case and is accused for offence under Article 8(2)(b)(ii) of Rome
Statute of ICC.
 Mr. Z Karmonic has committed the offence of War Crimes under Article 8(2)(b)
(iv) by intentionally launching an attack against the nuclear energy plants of
Rokumba with the knowledge and intention of causing incidental loss of life and
injury to civilians and widespread, long-term and severe damage to the natural
environment that is excessive to the concrete and direct military advantage
anticipated.
1. Article 8(2)(b)(iv) of the Rome Statute of ICC reads as under:-
“For the purpose of this Statute, “War Crimes” means:-
(b) Other serious violations of the laws and customs applicable in
international armed conflict, within the established framework of
international law, namely, any of the following acts:-
iv. Intentionally launching an attack in the knowledge that such attack will
cause incidental loss of life or injury to civilians or damage to civilians
objects or widespread, long-term and severe damage to the natural
environment which would be clearly excessive in relation to the
concrete and direct overall military advantage anticipated.”15
It may be seen here that it is very clear in a reasonable mind that the
occurrence of blasts in nuclear power plants will not only affect the human
resources but also the natural resources, i.e., flora and fauna. The chemicals

which were leaked because of the blasts occurred in thermal power plants had
caused serious existential threats in the surrounding areas and primarily was
responsible for death of aquatic animals. The air was not for the purpose of
breathing, majority of the human resources was knocking the doors of
15. Rome Statute of ICC
Hospital which were already filled up but was unable to provide electricity
because the same was not available in the whole Rokumba country. It was
further stated that probably it would not be possible to restore the affected
areas back to its pristine glory in the next two decades.16
2. It is further important to mention here that the respondent was the master mind
behind such incident. It can be noticed from the fact that he was the head of the
cyber wing of the government of Sohulwa, the ten super computers were
installed in his tenure, through which the process of cyber manipulation has
been done and the blasts have occurred. In such circumstances, the situations
are clearly pointing out the culprit, i.e., the respondent and the respondent is
liable to be punished for war crime under Article 8(2)(b)(iv).

16. Moot Problem, Page 13- Para 3
PRAYER
WHEREFORE IN THE LIGHT OF THE ISSUES RAISED, ARGUMENT ADVANCED,
REASONS GIVEN AND AUTHORITIES CITED, THIS HON’BLE COURT MAY BE
PLEASED TO:
To Hold
i- The respondent may kindly be convicted for the offence of Genocide under the
provisions of Article 6(a) of Rome Statute of ICC.
ii- The respondent may kindly be punished and convicted for offence of War Crime
under Article 8(2)(b)(ii) and Article 8(2)(b)(iv) of the Rome Statute of ICC.
Any other relief which this Hon’ble Court deems fit in the peculiar set of
facts and circumstances of the case may also kindly be provided in favour of
prosecution in the interest of justice.

ALL OF WHICH IS RESPECTFULLY SUBMITTED.

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19TH HENRY DUNANT MEMORIAL MOOT COURT COMPETITION 2019

IN THE HON'BLE INTERNATIONAL CRIMINAL COURT

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

night of 25 May, 2018?

Article 8(2)(b)(ii) by intentionally directing attack against nuclear energy?

Article 8(2)(b)(iv) by intentionally launching an attack against the nuclear energy

natural environment that is excessive to the concrete and direct military

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

ICC International Criminal Court

ICJ International Court of Justice.

ICRC International Committee of the Red Cross

ILA International Law Association

ILC International Law Commission

UNSC United Nation Security Council

SoS Sarozula Of Sohus

PCIJ Permanent Court Of International Justice

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

4. Goran Jelisid, Case No. IT-95-10A, Appeal Judgement, 5 July 2001

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

approached the Hon’ble Court has been reiterated herein below.

Crimes within the jurisdiction of the Court

this statute with respect to the following crimes:-

(a) The Crime of Genocide;

(b) Crimes against Humanity;

(c) War Crimes;

(d) The Crime of Aggression.

in accordance with the provisions of this statute if:

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

committed is referred to the Prosecutor by the Security Council acting under

Chapter VII of the Charter of the United Nations

night of 25 May, 2018?

Article 8(2)(b)(ii) by intentionally directing attack against nuclear energy?

Article 8(2)(b)(iv) by intentionally launching an attack against the nuclear energy

natural environment that is excessive to the concrete and direct military

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

case are summarized as follows:

 Country Sohulwa is a democratic country and it is situated at the eastern coast of

continent Z. This eastern portion of continent Z comprises of 4 countries, namely

Sohulwa, Sambhota, Zumanja and Rokumba. This portion of continent Z is also

boundary in the east.

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

border of Sohulwa and Rokumba. R2 is in south to R1 and it is further required to

II. TREATY OF SAROZULA

III. DEMARCATION OF LfS

fulfilling the food requirements of all the countries.

IV. EMERGENCE OF SoS

case is a glaring example of how a group promoting a particular religion leads to a

series of crimes which are against the humanity at large.

three countries. The widespread function of promoting a particular religion was in

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

banned the SoS group.

V. MR. Z. KARMONIC- THE CULPRIT

Sambhota and Zumanja.

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

Rokumba religion. After investigation, it was found by the Committee constituted by

originated from Sohulwa territory.

VI. TRIAL BEFORE THE HON’BLE INTERNATIONAL CRIMINAL COURT

the aforesaid charges.

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION

night of 25 May, 2018?

committed with intent to destroy, in whole or in part, a national, ethnical, racial or

led down by SoS previously also.

-WRITTEN SUBMISSION ON BEHALF OF THE PROSECUTION